MOTION FOR ENTRY OF DEFAULT, PARTIAL JUDGMENT AND FOR AN ORDER DIRECTING DEFENDANT TO TURN OVER MONTHLY FRINGE BENEFIT CONTRIBUTION REPORTS

NOW COME Plaintiffs, by their attorneys, and move for entry of judgment by default against Defendant, ENGEL HEATING, LLC, an Illinois limited liability company, in the total amount of $36,939.83, plus Plaintiffs' court costs and reasonable attorneys' fees in the amount of $939.25.

Further, Plaintiffs move for entry of an order directing ENGEL HEATING, LLC, an Illinois limited liability company, Defendant herein, to turn over monthly fringe benefit contribution reports due for the months of September 2011 through the present date, pursuant to the Agreements and Declarations of Trust to which Defendant is bound, said Defendant having failed to answer or other- wise plead to the Complaint and the monthly contribution reports being required in order to fully liquidate Plaintiffs' claims.

On January 16, 2012, the Summons and Complaint was served on the Registered Agent (by tendering a copy of said documents to his receptionist, Amanda Orlandini, who was authorized to accept service) at his place of business (a copy of the Summons and Affidavit of Service is attached hereto). Therefore, Defendant's answer was due on February 6, 2012. As Defendant has failed to timely answer the Complaint, Plaintiffs respectfully request entry of default, partial judgment and an order directing Defendant to turn over monthly fringe benefit contribution reports.

The undersigned, an attorney of record, hereby certifies that she electronically filed the foregoing document (Motion) with the Clerk of Court using the CM/ECF system, and further certifies that I have mailed the above-referenced document by United States Mail to the following non-CM/ECF participant on or before the hour of 5:00 p.m. this 16th day of February 2012:

Our website includes the first part of the main text of the court's opinion.
To read the entire case, you must purchase the decision for download. With purchase,
you also receive any available docket numbers, case citations or footnotes, dissents
and concurrences that accompany the decision.
Docket numbers and/or citations allow you to research a case further or to use a case in a
legal proceeding. Footnotes (if any) include details of the court's decision. If the document contains a simple affirmation or denial without discussion,
there may not be additional text.

Buy This Entire Record For
$7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.